[WSBARP] NV LLC Holding WA Real Property

Tue Oct 21 17:29:05 PDT 2025

I agree with Tim, and I think the "without more" exception would naturally
mean rental.

You can also work backward from the requirements for business licensing in
WA, which would cover generating revenue of $12k or more per year.  If you
meet that threshold, then you need a business license.  If you need a
business license, it would seem hard to argue that you're not transacting
business in WA.

-Paul Okner
*Fremont Law PLLC*
3429 Fremont Pl. N.,  Suite 305
Seattle, WA 98103
(206) 399 - 1922

On Tue, Oct 21, 2025 at 5:19 PM Timothy Steen <tsteen at andersonhunterlaw.com>
wrote:

> Assuming a traditional landlord/tenant rental relationship exists, then I
> believe registration is required since the LLC is transacting business in
> WA, rather than just holding the property. See RCW 23.95.505(1), (5).
>
>
>
> Best,
>
>
>
> Tim
>
>
>
> [image: A black sign with white text Description automatically generated]
>
> *Timothy E. Steen*
>
> *Attorney | Anderson Hunter Law Firm*
>
> 2707 Colby Avenue #1001 | Everett, WA  98201
>
> P.  (425) 252-5161 | D.  (425) 303-3125 | F.  (425) 258-3345
>
> | www.andersonhunterlaw.com
>
>
>
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> *From:* wsbarp-bounces at lists.wsbarppt.com <
> wsbarp-bounces at lists.wsbarppt.com> *On Behalf Of *Jan Kelly
> *Sent:* Tuesday, October 21, 2025 5:00 PM
> *To:* WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
> *Subject:* Re: [WSBARP] NV LLC Holding WA Real Property
>
>
>
> Thank you, but does having a tenant rise to the “more” part of this
> exception?
>
>
>
> (j) Owning, without more, property;
>
>
>
>
> *Jan Kelly, JD, MBA *Attorney at Law
>
> JK Law
> PO Box 1964
> Poulsbo, WA 98370
> Direct Line (702) 338-6733
>
> *Licensed in Nevada and Washington*.
>
>
>
> THIS EMAIL MESSAGE AND ANY ATTACHMENTS ARE CONFIDENTIAL AND INTENDED ONLY
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>
> *From:* wsbarp-bounces at lists.wsbarppt.com <
> wsbarp-bounces at lists.wsbarppt.com> *On Behalf Of *Timothy Steen
> *Sent:* Tuesday, October 21, 2025 4:53 PM
> *To:* WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
> *Subject:* Re: [WSBARP] NV LLC Holding WA Real Property
>
>
>
> Jan,
>
>
>
> See the exception in RCW 23.95.520(1)(j).
>
>
>
> Best,
>
>
>
> Tim
>
>
>
> [image: A black sign with white text Description automatically generated]
>
> *Timothy E. Steen*
>
> *Attorney | Anderson Hunter Law Firm*
>
> 2707 Colby Avenue #1001 | Everett, WA  98201
>
> P.  (425) 252-5161 | D.  (425) 303-3125 | F.  (425) 258-3345
>
> tsteen at andersonhunterlaw.com| www.andersonhunterlaw.com
>
>
>
> This email message may contain confidential and privileged information.
> Any unauthorized use is prohibited.  If you are not the intended recipient,
> please contact the sender by reply email and destroy all copies of the
> original message.  To comply with IRS regulations, we advise you that any
> discussion of Federal tax issues in this e-mail is not intended or written
> to be used, and cannot be used by you, (a) to avoid any penalties imposed
> under the Internal Revenue Code or (b) to promote, market or recommend to
> another party any transaction or matter addressed herein.  We do not
> accept service of any kind by e-mail unless expressly authorized in writing
> by the attorney of record.  E-mail communications are not intended to
> create contracts or CR 2A agreements.  All such agreements must be signed
> by the attorney of record.  Thank you.
>
>
>
> *From:* wsbarp-bounces at lists.wsbarppt.com <
> wsbarp-bounces at lists.wsbarppt.com> *On Behalf Of *Jan Kelly
> *Sent:* Tuesday, October 21, 2025 4:22 PM
> *To:* wsbarp at lists.wsbarppt.com
> *Subject:* [WSBARP] NV LLC Holding WA Real Property
>
>
>
> I am conveying a rental property here in WA to a Nevada LLC. Does the NV
> LLC need to file a foreign registration to do business here, even if it is
> just holding property?
>
>
>
> Thank you.
>
>
>
>
> *Jan Kelly, JD, MBA *Attorney at Law
>
> JK Law
> PO Box 1964
> Poulsbo, WA 98370
> Direct Line (702) 338-6733
>
> *Licensed in Nevada and Washington*.
>
>
>
> THIS EMAIL MESSAGE AND ANY ATTACHMENTS ARE CONFIDENTIAL AND INTENDED ONLY
> FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY
> CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM
> DISCLOSURE UNDER APPLICABLE LAW. Any unauthorized review, use, copying,
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